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The Process of Development of IPPC Legislation. Robert Sarlamanov MA, IPPC Expert Ministry of Environment and Physical Planning, Bercen Exchange Programme, Prague, October, 2004. The Law on Environment and Nature Protection and Promotion (still in force);

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The process of development of ippc legislation

The Process of Development of IPPC Legislation

Robert Sarlamanov MA, IPPC Expert

Ministry of Environment and Physical Planning,

Bercen Exchange Programme, Prague, October, 2004

Situation until september 2002

The Law on Environment and Nature Protection and Promotion (still in force);

Single declarative provision on IPPC;

No subsidiary legislation;

No templates;

Technical-environmental studies in place;

Situation until September, 2002

Ippc in the macedonian legislation

Current legislation: (still in force);

Act for protection and improvement of the environment” (Articles 28 and 30);

Forthcoming legislation

Law on Environment – Chapter on: Integrated Environmental Permitting and Chapter on Adjustment Plans;

Special Laws on air quality, water, waste management

IPPC in the Macedonian Legislation

Process of development of national ippc regulation

September, 2002 – September, 2004; (still in force);

Multidisciplinary approach;

Multi-sectoral approach;


Public Involved

Process of Development of National IPPC Regulation

Industry other stakeholders involved

Leaving the old “command & control” policy; (still in force);

Adopting the DIALOG policy with the industry and the public in general;

The goal – high level of protection of environment as a whole

Industry & other Stakeholders Involved


GAP Analysis; (still in force);


Stakeholders’ participation;


Entering governmental procedure;

1st reading in the Parliamentarian commissions;

Public debates;

Stakeholders, comments

Final drafting;

Table of concordance;

Parliamentary Procedure;

Adopting the Law



The Law on Environment (still in force); (IPPC regulation);

IPPC Decree (issued by the Government, defining the list of A and B IPPC activities and the applying schedule);

IPPC Ordinance (issued by the MEPP, defining the procedure and templates)


Supporting results

Finalised: (still in force);

National Inventory of current A IPPC Installations;

IPPC Brochure

Draft versions:

IPPC Manual (Internal and external);

IPPC Guide for Industry

Preparatory phase:

Manual for development of Adjustment Plans;

Pilot Integrated Environmental Permit

Supporting results


Done: (still in force);

70% of the potential IPPC Installations visited;

Training for the MEPP IPPC related employees;

IPPC Seminar for the Industry


Training for IPPC related MEPP employees;

Training for LSGU staff;

Training seminar for each IPPC sector

Other activities:

Training for IPPC experts (BAS action);

Development of Adjustment plans for 250-300 SME through BAS trained consultants


Defines and precise the: (still in force);

Activities under IPPC regulation (A and B);

Significant changes of the existing installations???;

Time-schedule for applying for an Integrated Environmental Permit or Adjustment permit;

Environmental score sheet for determining the charges

IPPC Decreefor Determining the Installations for which an Integrated Permit is required and Time Schedule for submission of the Adjustment Plans

Adjustment plan

What is it: (still in force);

Obligation for Operators that will apply for Adjustment permit;

Sets the operating conditions of the installation including the ELV and EQS to all environmental media;

Sets the time schedule for applying the conditions;

Determines BAT for the concerned location;

Considers the best practices for the existing technology;

Plan how to reach BAT in sustainable way

Adjustment Plan

Type of permits

Installations falling under A list of activities: (still in force);

A Integrated environmental permit (new installations);

A Adjustment permit with approved Adjustment Plan (existing installations)

Installations falling under B list of activities:

B Integrated Environmental Permit (new installations);

B Adjustment Permit with approved Adjustment Plan (existing installations, based on lower BAT standards;

Type of Permits

Schedule for applying for integrated adjustment permit

The schedule for applying for Adjustment Permit is being developed according:

Assessment of the economic impact from IPPC Implementation (including productivity factor);

General assessment of the technical level in IPPC sectors (both: technology used and techniques applied);

Pollution risk assessment by different IPPC sectors and different installations

Schedule for Applying for Integrated/Adjustment Permit

Applying schedule
Applying schedule developed according:






Start 01.01.06

END of applying 31.12.08






WASTE management

Adjustment period implementation plan
Adjustment Period - Implementation Plan developed according:

B A T level




END of applying 31.12.08

Start 01.01.06

END of adjustment period 01.04.14



WASTE management

Ippc implementation plan

Existing Installations: developed according:

Compliance with BAT norms by development of an Adjustment Plan (2006-2009) and their implementation until April, 2014, or

Comply with BAT standards immediatelyandApply directly for Integrated Environmental Permit

New Installations:

For new installations (2006-01.07.2007) by choice:

Immediately BAT or

Adjustment Plan

For new installations after 01.07.2007, immediate compliance with BAT

IPPC Implementation Plan

Charges determination

Criteria for charging an individual installation: developed according:

Environmental impact (emissions to air, water, soil and other influences);

Environmental management (EMAS, ISO 14000, not certified);

Sensitivity of receptors (close to inhabited or protected area);

Other criteria – eco-labeling or voluntary agreement

Charges determination

Ippc ordinance for regulating the procedure for obtaining a integrated environmental permit
IPPC Ordinance developed according: for Regulating the Procedure for obtaining A Integrated Environmental Permit

  • Format and the content of the Registar of A Permits;

  • Format and the content of the Application for Integrated/Adjustment Permit;

  • Applying Procedure;

  • Procedure in case of trans-boundary impact.

  • Content of the A Integrated/Adjustment Perrmit;

  • Content of the Adjustment Plan;

  • Procedure for negotiation on the Adjustment plan conditions;

Pr ocedu r e

Look if developed according:

installation is

under IPPC

Pr ocedu r e


Preparation for

applying for



D i ag r am

Submission of

application to

the Regulator

Assessment of

Additional data required


the Application


ent of the




of the





between the

Operator and

the Regulator

Decision on

issuing of an





of the Permit

Implementation remarks

Advantages: developed according:

Good overview of the situation;

Legislation and sub-legislation ready

Awareness materials distributed;

Training programmes for administration and consultants;

Covering 50% of the costs for development of the Adjustment Plans;

Relatively long adjustment period

Implementation remarks

Implementation remarks1

Disadvantages and risks: developed according:

Bad socio-economic factors in most of the sectors;

Low enforcement capacities;

Low administrative capacities especially on municipal level

Possible resistance from the industry;

Possible low consultant capacities;

Relatively short implementation period for certain installations

Implementation remarks

Thank you developed according: Robert Sarlamanov, [email protected] ++ 389 70 69 69 89work: ++ 389 2 3066 930 ext:128